In re E.W., 2017 Ohio 5623

Mother (Sara N.) has a history of bipolar disorder with psychosis, dependent and borderline personality disorders, unstable housing, and involvement with abusive or criminal romantic partners; E.W. born Oct. 29, 2013.
E.W. entered the child-services system at ~13 months; parents agreed to dependency and temporary custody to Medina County JFS; child lived with paternal grandparents throughout the case.
Case plan required Mother to engage in counseling and services to address insight into unsafe relationship choices; Mother attended counseling but stopped psychiatric meds when she became pregnant and continued to associate with men convicted of sex offenses.
MCJFS moved for legal custody to Grandparents; Mother sought a six-month extension of temporary custody to continue case-plan work.
At hearings, witnesses noted limited and minimally interactive supervised visitation by Mother; Grandparents provided stable, bonded, long-term care; guardian ad litem recommended legal custody to Grandparents as in the child’s best interest.
Trial court awarded legal custody to Grandparents; Mother appealed, raising (1) improper amendment of the case plan without written notice and (2) error in granting legal custody rather than extending temporary custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court improperly adopted an amended case plan without prior written notice under R.C. 2151.412(F)(2)	Mother: MCJFS amended the case plan without giving statutorily required written notice, so adoption was invalid	MCJFS: Mother did not object at the hearing and agreed to the amendments	Court: Overruled — Mother (through counsel) expressly agreed at the hearing, so she waived the notice defect
Whether the court erred by awarding legal custody to Grandparents instead of extending temporary custody for six months	Mother: Court should have extended temporary custody to allow her to make further progress on the case plan	MCJFS/Grandparents: Mother had not made "significant progress"; child needed permanence; Grandparents could provide stable home	Court: Overruled — evidence showed lack of significant progress and best interest favored legal custody with Grandparents

The opinion cites several Ohio child-custody/juvenile decisions for guidance (e.g., In re K.H., In re N.P., In re Fulton, In re B.G., In re T.A., In re R.G.), but it does not provide official reporter citations for those cases in the published entry.